Policies, Codes and Compliance

POLICIES & CODES

Recognizing the vital importance of conducting its business subject to high ethical standards and in full compliance with all applicable laws and, even where not required by law, with integrity and honesty, Signet has adopted a Code of Ethics applicable to the Chairman, the independent Directors, the Chief Executive Officer, the Chief Financial Officer and other senior officers of Signet Jewelers Limited and its subsidiaries and affiliates.

The Company has also adopted a Code of Conduct that applies to directors, officers and employees of the Company. The Chairman, the Independent Directors, the Chief Executive Officer, the Chief Financial Officer and other senior officers of the Company that are subject to this Code of Ethics are also subject to the Code of Conduct.

This Code Conduct is designed to promote honest, ethical and lawful conduct by all employees, officers and directors of Signet Jewelers and all subsidiaries and entities controlled by it. The Code is intended to help employees, officers and directors understand the Company’s standards of ethical business practices and to stimulate awareness of ethical and legal issues that may be encountered in carrying out their responsibilities.

Signet Jewelers has the objective to operate as a profitable and responsible specialty jewelry retailer, delivering increasing value to our shareholders, while seeking to uphold our Social, Ethical and Environmental Principles and considering the interests of our other stakeholders: customers, employees, those with whom we do business, and society as a whole.

In seeking to achieve our objective we recognize that there are indirect impacts generated by our activities, in particular through our supply chain. We will seek to use our influence with those with whom we do business directly, in particular our agents and suppliers, to promote the achievement of our Social, Ethical and Environmental Principles. As a customer we believe we have an opportunity to seek to influence the social, ethical and environmental performance of our suppliers in a positive manner. In order to do so it is necessary that our suppliers, and in turn their suppliers, should understand Signet’s standards as set out in this Code. Therefore, we encourage suppliers to ensure that this Code is communicated throughout our supply chain.

COMPLIANCE WITH U.S. & INTERNATIONAL LEGISLATION & REGULATIONS

Signet Trading Limited Gender Pay Information – Publication for the period including 5th April 2018

UK gender pay reporting legislation requires employers with 250 or more employees to publish statutory calculations every year showing how large the average pay gap is between their male and female employees.

The analysis is based on data as of 5th April each year.

The gender pay gap shows the differences in the average (mean and median) earnings between men and women. This is different to equal pay. Equal pay requires that men and women who carry out the same jobs; or equivalent jobs, are paid the same.

Signet Trading Limited has published the following gender pay data on GOV.UK

European Union (EU) Conflict Minerals Legislation

In May 2017, the EU passed “conflict minerals legislation” to ensure that minerals and metals exported to the EU do not contribute to conflict, that smelters and refiners in the EU and globally do not use raw materials from sources which may contribute to conflict, and that mine workers are not abused.

The law also supports the development of local communities. The law requires EU companies to ensure they import these minerals and metals from responsible sources only.

The law will be enforced from January 1, 2021 and Signet is confident that our already robust processes and procedures will ensure compliance with this legislation.

Modern Slavery Act 2015 (UK)

Signet Trading Limited expects its business suppliers to comply with the applicable laws and regulations of the United Kingdom and those of the respective country of manufacture or exportation. In accordance with the requirements of the Modern Slavery Act 2015, consumers will find below details of the steps Signet is taking to address slavery and human trafficking in its direct supply chain.

Engagement in verification of product supply chains to evaluate and address risks of human trafficking and slavery:

Signet conducts risk assessments of its significant suppliers in its effort to evaluate and address risks of human trafficking and slavery. These risk assessments are conducted by independent external third parties. If potential risks are identified, a course of action is determined to best address them.

Auditing of suppliers to evaluate compliance with company standards for trafficking and slavery in supply chains:

Many of Signet’s largest suppliers are certified members of the Responsible Jewellery Council (RJC), as Signet encourages all its suppliers to be. Suppliers that are certified RJC members receive scheduled audits by independent third party firms as part of a rigorous and fulsome RJC Code of Practices certification process. Significant suppliers that are not certified members of RJC are audited by independent third party firms who conduct audits that, while announced, are only announced with sufficient advance notice to permit access. In addition, for all suppliers, purchase order terms and conditions include statements regarding compliance with all laws. By agreeing to these terms and conditions, our suppliers confirm their understanding and agreement to these compliance standards.

Compliance with the laws regarding slavery and human trafficking of the country or countries in which they are doing business:

Signet suppliers are asked to agree to adhere to the respective laws regarding human trafficking and slavery.

Maintenance of internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking:

Signet expects all employees to adhere to and comply with all laws which would include such laws related to human trafficking and slavery. Management is responsible for ensuring that all employees are aware of and adhere to a code of conduct which includes compliance with all laws. Any known incidences where an employee does not do so, appropriate disciplinary action is taken.

Training on human trafficking and slavery for company employees and management who have direct responsibility for supply chain management, particularly with respect to mitigating risks within the supply chains of products:

All Signet employees responsible for supply chain-related decisions and product purchasing are required to complete training and assessment programs that are geared to enhance their knowledge of various compliance matters. These programs include identifying and addressing human trafficking and slavery in Signet direct supply chains.

California Transparency in Supply Chains Act of 2010

Signet Jewelers Ltd expects its business suppliers to comply with the applicable laws and regulations of the United States and those of the respective country of manufacture or exportation. Per the California Transparency in Supply Chains Act of 2010 (SB 657), below consumers will find a disclosure of the efforts Signet is taking to address slavery and human trafficking in its direct supply chain.

Engagement in verification of product supply chains to evaluate and address risks of human trafficking and slavery:

Signet conducts risk assessments of its significant suppliers in its effort to evaluate and address risks of human trafficking and slavery. These risk assessments are conducted by independent external third parties. If potential risks are identified, a course of action is determined to best address them.

Auditing of suppliers to evaluate compliance with company standards for trafficking and slavery in supply chains:

Many of Signet’s largest suppliers are certified members of the Responsible Jewellery Council (RJC), as Signet encourages all its suppliers to be. Suppliers that are certified RJC members receive scheduled audits by independent third party firms as part of a rigorous and fulsome RJC Code of Practices certification process. Significant suppliers that are not certified members of RJC are audited by independent third party firms that conduct audits that, while announced, are only announced with sufficient advance notice to permit access. In addition, for all suppliers, Purchase Order Terms and Conditions include statements regarding compliance with all laws. By agreeing to these terms and conditions, our suppliers confirm their understanding and agreement to these compliance standards.

Compliance with the laws regarding slavery and human trafficking of the country or countries in which they are doing business:

Signet suppliers are asked to agree to adhere to the respective laws regarding human trafficking and slavery.

Maintenance of internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking:

Signet expects all employees to adhere to and comply with all laws which would include such laws related to human trafficking and slavery. Management is responsible for ensuring that all employees are aware of and adhere to a code of conduct which includes compliance with all laws. Any known incidences where an employee does not do so, appropriate disciplinary action is taken.

Training on human trafficking and slavery for company employees and management who have direct responsibility for supply chain management, particularly with respect to mitigating risks within the supply chains of products:

All Signet employees responsible for supply chain-related decisions and product purchasing are required to complete training and assessment programs that are geared to enhance their knowledge of various compliance matters. These programs will be supplemented in 2012 to include identifying and addressing human trafficking and slavery in Signet direct supply chains.

Signet Jewelers Limited filed a “DRC Conflict Free” Conflict Minerals Report (“CMR”) with the U.S. Securities and Exchange Commission (“SEC”) as part of its Specialized Disclosure Report (“Form SD”) filed on May 31, 2017.

In accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”), Signet filed a Form SD and an accompanying, independently audited CMR stating that Signet has determined that its jewelry and gift products containing gold, tin, tungsten, or tantalum (“3Ts”) are “DRC conflict-free” as defined by Section 1502 of the Dodd-Frank Act (which added a new Section 13(p) to the Securities Exchange Act of 1934) and Rule 13p-1 and Form SD promulgated by the SEC under this statute.

The CMR states that through the exercise of due diligence, Signet has identified sources of gold and 3Ts in its supply chain which originated, or may have originated, in the Democratic Republic of the Congo and neighboring countries, and has determined that all of these sources qualify as DRC conflict-free for purposes of Section 1502 of the Dodd-Frank Act, the SEC’s rules thereunder and internationally recognized industry guidance and standards.

Signet believes that a responsible, conflict-free supply chain is fundamental to the reputation of the jewelry industry, not just to Signet and is, therefore, committed to continuing our longstanding efforts to advance responsible sourcing throughout the jewelry industry supply chain.

Did you know?

Signet’s employees are key to our ability to achieve our objectives and mission. In recognition of this, teamwork, integrity, communication and fair treatment of employees all play an important part in the success of Signet.

Signet is a founding and certified member of the Responsible Jewellery Council (RJC), which provides an efficient way of addressing supply chain issues on an industry-wide basis. The RJC effectively enables industry-wide co-operation to manage Social, Ethical and Environmental risks at the mining, trading and secondary processing phases of the jewelry and gemstone supply chain.

Signet has established Responsible Sourcing Protocols for all our suppliers, which ensure that none of the gold (or tin, tungsten or tantalum) that we sell contributes to conflict anywhere in the world. All of our global suppliers must comply with these protocols, which are recognized by leading international organizations.

Signet is a founding and certified member of the Responsible Jewellery Council (RJC) and remains dedicated to the objective of reinforcing consumer confidence in the diamond and gold supply chain. From an initial membership of fourteen companies there are now approximately 440 companies encompassing all aspects of the supply chain from the mining companies to retailers. A key membership requirement of the RJC is an independent assessment of compliance with the Code of Practices.
Since RJC’s founding in 2005, Signet has strongly encouraged its suppliers and other members of the industry to join the RJC and eventually become certified members which more than 300 have done.

Signet’s Supplier Code of Conduct sets out the company’s expectation that suppliers should respect the Fundamental Conventions of the International Labour Organization and the UN Declaration of Human Rights. Signet is engaged at a senior executive level to address human rights in the jewelry supply chain on an industry-wide basis directly with civil society and government and through the Responsible Jewellery Council.